Q: …So your whistleblowing belief is based upon …. two aspects of Keith’s personal life, his compulsive gambling and his sexual behavior?…

A: Correct.

Q: Why do you think you have the right to go to the press and expose anybody’s personal life about their sexual behavior?

A: ….I didn’t do it with the press. I’ve talked to the press a couple of times.

Q: About Keith’s sexual behavior?

A: Correct. But that was already well-known before I ever talked to the press.

Q: What gives you the right to go to the press or any third party to talk about anybody’s sexual behavior?

A: …. Keith represents himself as one thing. And… had he fully disclosed that (sexual promiscuity with multiple women) are activities that he participated in, I would have never bought a program. I would have never opened a center for them….

Q: … You talk about people’s sex lives…. You talk about their gambling addictions.

A; I don’t do that on a general basis.

Q: But you do that on a specific basis.

A: Right, because Keith Raniere is a figurehead — and he runs a company that deals with people on an emotional level, and I believe that those things need to be known.

Q: I can tell you I would find it deeply offensive if somebody talked about my sex life in public. And so when you went and spoke to the press about Keith’s sex life in public, you were attempting to hurt him; correct?

A: No, that’s not true. I was attempting to inform people. And the thing is, is that was already out there….

Q: So you felt justified in talking to the press about Keith’s sex life because others were doing it?

A: I believe that I was informing the public, which is my First Amendment right to do.

Q: Do you believe you had the right to talk about Keith Raniere’s sex life to various reporters because his disgruntled girlfriends were doing the same thing?

A: I believe that I had a right to tell people that because I had sold hundreds of people on Keith’s character. And so I believe that I had a right to warn the public because I would want to know that if I was going to enroll in a program where somebody was selling him as a Buddhist monk kind of figure.